RE: The tariff classification of a high ropes course system from Germany

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364886 October 6, 2026 CLA-2-95:OT:RR:NC:N4:462 CATEGORY: Classification TARIFF NO.: 9506.99.6080 Michael Haller KristallTurm GmbH & Co. KG An der Bretonenbrucke 8 Lenggries, Bavaria 83661 Germany RE: The tariff classification of a high ropes course system from Germany Dear Mr. Haller: In your letter dated September 8, 2026, you requested a tariff classification ruling. Images and product literature were provided in lieu of a sample. The product under consideration is described as a modular freestanding high ropes course system designed for recreational climbing and balancing activities. The system consists of structural steel poles and related structural components, platforms, timber components, steel cables, ropes, climbing and balancing elements, connection hardware, and related safety-system components. After being fitted with personal protective equipment and receiving a safety briefing, participants ascend to the elevated course where they choose a route and cross successive suspended challenge elements by climbing, balancing, stepping, crawling, gripping, or otherwise moving to reach the next platform between elements. They continue to choose successive routes and challenges until finally exiting the course. Per your submission, seven product families of the high ropes course system are available, including the KT-6, KT-7, KT-10, KT-12, KT-13, KT-14, and KT-18 configurations. The product families vary in the number and arrangement of poles, platforms, levels, and challenge elements. Compact versions of each product family, with a 20% smaller footprint, are also available. The system may be used as a standalone attraction or utilized at a resort, zoo, municipal recreation site, or amusement park. It will be imported unassembled and may be shipped in multiple containers due to the size of the merchandise. In your request, you suggest classification under subheading 9506.91.0030, Harmonized Tariff Schedule of the United States (HTSUS), which provides for articles and equipment for general physical exercise, gymnastics or athletics. While we agree that the high ropes course system is appropriately classified under heading 9506, HTSUS, we disagree with classification under 9506.91.0030, HTSUS. Though participants will get a workout on the high ropes course, it is not considered gym equipment. Rather, it is akin to playground equipment intended to facilitate physical recreation, which CBP has consistently classified under subheading 9506.99, HTSUS. See HQ H225359 (July 25, 2018) and N300929 (October 30, 2018). The applicable subheading for all variants of the high ropes course system will be 9506.99.6080, HTSUS, which provides for "Articles and equipment for general physical exercise, gymnastics, athletics, other sports…or outdoor games…; swimming pools and wading pools; parts and accessories thereof: Other: Other: Other…Other." The general rate of duty will be 4% ad valorem. The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 CFR 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Sandra Walia at sandra.s.walia@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division